Part 2

Trading income
Chapter 13

Deductions from profits: unremittable amounts

Withdrawal of relief
191
1
This section applies if—
a
some or all of an unremittable amount has been deducted from profits under section 189, and
b
any of the following events occurs.
2
The events are that—
a
the amount or part of it ceases to be unremittable,
b
the amount or part of it is used to finance expenditure or investment outside the United Kingdom,
c
the amount or part of it is applied outside the United Kingdom in another way,
d
the amount or part of it is exchanged for, or discharged by, an amount that is not unremittable,
e
a deduction is allowed in respect of the amount or part of it under section 35 (bad and doubtful debts), and
f
if the amount is an amount owed, a payment under a contract of insurance is received in relation to the amount or part of it.
3
The amount or the part of it in question is brought into account as a receipt in calculating the profits of the trade for the period of account in which the event occurs, but only so far as—
a
it has been deducted from profits under section 189, and
b
it has not already been brought into account as a receipt in calculating the profits of the trade as a result of this section.
4
If the event is the receipt of a payment under a contract of insurance, the amount brought into account as a receipt must not exceed the amount of the payment.